What Article 77 requires
Article 77 requires that every battery in scope carries a digital product passport — a structured electronic record of the battery's identity, composition, carbon footprint, performance, supply-chain due diligence and end-of-life information. The passport is reached through a data carrier (a QR code) on the battery, which resolves to the passport via a unique identifier assigned at item level.
The obligation becomes binding on 18 February 2027. From that date a battery placed on the EU market without a conforming passport is non-compliant, which can mean denied market access, fines set by each Member State, and recalls.
Who must comply
The duty falls on the economic operator that places the battery on the EU market or puts it into service — typically the manufacturer, or the importer when the cells or pack are made outside the EU. That operator assigns the unique identifier and is responsible for the passport's content and availability.
Importers carry the same obligation as manufacturers: if you import a battery into the EU, the passport is your responsibility even when the overseas maker never produced one. This is the most common compliance gap — and the case TracePass is built for: assemble a conforming passport from the supplier's technical documentation, and request the data only the supplier holds through a token-based supplier portal.
What data the passport must carry (Annex XIII)
Annex XIII is the data specification. It covers battery identity, materials and chemical composition (including critical raw materials and substances of concern), the carbon footprint, performance and durability, supply-chain due diligence, recycled content, and end-of-life handling. Some data points are public; others are restricted to authorities or to operators with a legitimate interest, such as repairers and recyclers.
Not every field applies to every battery. Applicability is conditional: an EV battery carries the full set, while a light-means-of-transport (LMT) or industrial battery legitimately leaves some points empty where a provision does not apply. The TracePass battery template models the full Annex XIII structure across 91 fields and tracks each field's access level, so the passport exposes the right data to the right audience.
How the passport is accessed
The passport is reached by scanning the QR code on the battery, which encodes a unique identifier in the GS1 Digital Link form and resolves to the passport. Storage is decentralised: the full passport data stays with the economic operator (or an authorised service provider), while a central EU DPP Registry — operational from July 2026 — holds only the unique identifiers and the access-control metadata, and interconnects with market-surveillance systems so authorities can reach restricted data.
Article 77(3) sets the data-carrier and unique-identifier standards; these are being updated by delegated act, with current standards remaining valid as equivalents in the interim. TracePass serves each passport at a GS1 Digital Link URL with content negotiation — a human-readable page for browsers, JSON-LD for crawlers and authority systems — and applies the public / restricted / authority access tiers per field.
Getting Article 77-ready with TracePass
TracePass turns a cell or pack datasheet into a conforming Annex XIII passport: upload the technical documentation, the AI suggests values for the 91 fields with confidence scores, and a reviewer approves them — AI suggests, a human approves, nothing is auto-published. Data only the supplier holds (origin of critical raw materials, due-diligence attestations) is requested through a token-based supplier portal, with reminders, and written back into the passport.
On publish, each battery gets a GS1 QR code resolving to its passport at the right access tier, ready for the 18 February 2027 deadline. The full per-article mapping for the rest of the regulation is on the article-by-article coverage page.
Article 77 — frequently asked
- When does the Article 77 battery passport become mandatory?
- 18 February 2027. From that date every battery in scope placed on the EU market must carry a conforming digital passport.
- Who is responsible for the battery passport — the manufacturer or the importer?
- The economic operator placing the battery on the EU market. For batteries made outside the EU that is the importer, who carries the same obligation as a manufacturer even if the overseas maker never produced a passport.
- What data must the Article 77 passport contain?
- The data points in Annex XIII: battery identity, materials and chemical composition, carbon footprint, performance and durability, supply-chain due diligence, recycled content and end-of-life information — at public, restricted or authority access levels. Applicability is conditional on the battery category.
Reviewed by Malin Ivanov, Managing Director — on